CX Guidelines | Updates stemming from 2024 Consent Review changes #674
Comments
CDR-CX-Stream
changed the title
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We’re pleased to share for consultation the following draft guidance:
We invite community feedback via this thread. Your input, questions and comments will help us refine the guidance, allowing us to expedite their release following the finalisation of the rules and standards. Please remember that this guidance is shared in draft state, representing proposed rules and standards that have not been made. This should not be taken as definitive guidance of compliance, and should not be considered as legal or compliance references for the purpose of implementation. The original post has been updated to include these links. |
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Following the making of the amended rules and new standards, the DSB has prepared additional draft guidance for community feedback. In response to past requests for more descriptive information on what has changed in each release, we have provided draft Change Log wording below. We have also used symbols and markup in the annotations frame in Figma to help clarify what type of change has been made to the annotation. Please refer to the key at the top of the annotations frame for more details. Note that this format will only be used during this consultation window. Finalised and published guidance on the cx.cds.gov.au website will not include this level of detail. We seek feedback on the Change Log and marked up annotations, and whether participants find these valuable. Consent Management (Data recipient): Collection and use - Default example Updated CX artefacts and requirements relating to Consent Management (Data recipient): Collection and use - Default example. This includes:
We invite community feedback via this thread. Please remember that this guidance is shared in draft state. This should not be taken as definitive guidance of compliance, and should not be considered as legal or compliance references for the purpose of implementation. The original post has been updated to include these links. The CX team are working to finalise additional draft CX guidelines to reflect the published rules. These will be posted here in the coming weeks for community input. |
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The DSB has prepared additional draft guidance for community feedback. As outlined in the previous comment, we are providing draft Change Log, as well as using symbols and markup in the annotations frame in Figma to help clarify what type of change has been made to the annotation. We seek feedback on whether participants find these artefacts valuable for consultation. Collection and Use: Default example
Collection and Use: Using outsourced service providers Updated CX artefacts and requirements relating to Collection and Use Consent: Using outsourced service providers. This includes:
We invite community feedback via this thread. Please remember that this guidance is shared in draft state. This should not be taken as definitive guidance of compliance, and should not be considered as legal or compliance references for the purpose of implementation. The original post has been updated to include these links. |
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We have made minor amendments to annotations in the following flows, primarily to clarify transitional provisions and effective dates. [NEW] Notifications: CDR Receipts
[NEW] Notifications: 90 day notifications
Collection and Use: Using outsourced service providers
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The DSB has prepared additional draft guidance for community feedback. As outlined in previous comments, we are providing draft Change Log, as well as using symbols and markup in the annotations frame in Figma to help clarify what type of change has been made to the annotation. We seek feedback on whether participants find these artefacts valuable for consultation. Trusted Adviser Disclosure Consent: Detached Flow – Default example Updated CX artefacts and requirements relating to Trusted Adviser Disclosure Consent: Detached Flow – Default example. This includes:
Trusted Adviser Disclosure Consent: Bundled Flow Updated CX artefacts and requirements relating to Trusted Adviser Disclosure Consent: Bundled Flow. This includes:
We invite community feedback via this thread. Please remember that this guidance is shared in draft state. This should not be taken as definitive guidance of compliance, and should not be considered as legal or compliance references for the purpose of implementation. The original post has been updated to include these links. Edited 6 February 2025 to add 2 additional CX Guidelines relating to when the DH selection might occur in the Trusted Adviser Disclosure Consent: Bundled flow (new checklist references 1CO3.01.44 and 1CO3.01.45) |
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The DSB has prepared additional draft guidance for community feedback. As outlined in previous comments, we are providing draft Change Logs, as well as using symbols and markup in the annotations frame in Figma to help clarify what type of change has been made to the annotation. We seek feedback on whether participants find these artefacts valuable for consultation. Amending consent: Business consumer disclosure consent Updated CX artefacts and requirements relating to Amending consent: Business consumer disclosure consent. This includes:
Business Consumer Disclosure Consent: Detached Flow Updated CX artefacts and requirements relating to Business Consumer Disclosure Consent: Detached Flow – Default example. This includes:
Business Consumer Disclosure Consent: Bundled Flow New CX artefacts and requirements relating to bundled collect, use and business consumer disclosure consents. These artefacts provide implementation examples to reflect the updated rules relating to seeking consent. Accredited Person Disclosure Consent: Bundled Flow New CX artefacts and requirements relating to bundled collect, use and disclosure consents for accredited persons. These artefacts provide implementation examples to reflect the updated rules relating to seeking consent. Please remember that this guidance is shared in draft state. This should not be taken as definitive guidance of compliance, and should not be considered as legal or compliance references for the purpose of implementation. The original post has been updated to include these links. |
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The CX team has now posted the last draft CX Guidelines wireframes and Change Logs to this ticket for consultation. Please refer to the earlier comments for details of the draft flows, including draft change logs. The final list of wireflows for consultation are:
We now seek any final feedback or questions from the community on the flows shared by COB, Thursday 20 February 2025. After this date, the CX team will action any feedback received and finalise the flows. The CX team aims to update all CX Guidelines on the CX Guidelines website (including flows not consulted on as part of this CR) by mid-March 2025. Please note that these flows are still in draft format and are subject to change before being published on the CX Guidelines website. Thank you for your continued engagement. |
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Mastercard welcomes the opportunity to comment on this proposal. We note that Proposed CX Guideline 30 in the Business Consumer Disclosure Consent: Detached Flow indicates that requirements related to non‐accredited persons may be presented at any appropriate point in the consent flow. However, other CX standards appear to require that specific elements be provided within the consent flow itself. For example, CX Standard 25 mandates that Data Recipients advise consumers to review how non‐accredited persons will handle their data. If the intent is to allow some required elements to appear before consent or in CDR receipts or consumer dashboards rather than within the consent flow, we recommend that this be clearly stated. Conversely, if this is not the case, we also suggest clarifying the requirements accordingly. We note that similar CX Guidelines already exist (for example in the Business Consumer Disclosure Consent: Bundled Flow and the Trusted Advisor Disclosure Consent flows). |
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We are no longer accepting comments on this CR. Thank you everyone for your engagement. @MastercardOpenBankingAustralia, thank you for your question, we will come back to you with a clarification shortly. While no further comments will be considered before the guidelines are updated, CDR participants are welcome to create Change Requests asking for new or updated CX Guidelines, or clarifications to existing guidance, at any time. These will be considered and actioned as part of the usual maintenance iteration cycles. For more information, see the knowledge article on the CX Guidelines Consultation process. We will begin updating CX Guidelines on the cx.dsb.gov.au website over the coming weeks. When new and revised Guidelines are published, these will be noted in the home page's Announcements section. We will close this thread once all updated guidelines are published. |
Description
In August 2024, the Treasury conducted a consultation on proposed consent and operational enhancement amendments to the CDR Rules. The DSB simultaneously consulted on Decision Proposal 350 to outline the expected changes to the standards to support the proposed rules.
This issue outlines the anticipated updates to the CX Guidelines that will be required to reflect the expected rules and standards changes.
The community are invited to provide feedback on these draft CX guideline changes ahead of any final rules or standards changes to expedite their release. Additional requests for guidance to support the proposed rules and standards can also be made in this thread.
The final CX guidelines will necessarily adjust to the final rules or standards, and as such these draft artefacts are subject to change and should not be interpreted as finalised guidance.
N.B. the draft CX guidelines only outline where a proposed rule and standards change has an associated user interface or consumer experience component. As noted in DP350, CDR agencies will not provide guidance on the proposed nominated representative changes until any relevant rules are made.
Intention and Value of Change
The DSB publishes CX guidelines to assist participants with implementation of the CDR. The publication of draft CX Guidelines will allow the community to provide feedback on proposed changes and seek further clarifications where necessary.
Consulting on these draft guidelines before the associated rules and standards are finalised will allow their release to be expedited to facilitate implementation. The final artefacts will be published on the CX Guidelines website pending this consultation and the making of any final rules and standards.
These draft guidelines will be discussed with CDR agencies in conjunction with this consultation to ensure alignment before publishing.
N.B. The CX guidelines shared in this issue are in draft state and represent proposed rules and standards that have not been made. These wireframes should not be taken as definitive guidance of compliance with the rules and should not be considered as legal or compliance references for the purposes of implementation.
Areas affected
Changes are expected to impact all variants in the following areas of the CX guidelines:
New item or change proposed
Many changes will be mirrored across multiple flows. For example, many of the draft changes to the default data recipient dashboard will be also reflected in the other data recipient dashboard guidance, such as for amended consents, disclosure consents and withdrawals. As such, we intend to consult on the following subset of flows:
Collection and use consent: Default example
Collection and use consent: Using outsourced service providers
TA disclosure consent: Detached flow
TA disclosure consent: Consolidated flow
Amending consent: Business consumer disclosure consent
Consent Management (Data recipient): Collection and use - Default example
[NEW] Notifications: CDR Receipts
[NEW] Notifications: 90 day notifications
[NEWLY ADDED] AP Disclosure Consent: Bundled Flow
[NEWLY ADDED] Business Consumer Disclosure Consent: Detached Flow
[NEWLY ADDED] Business Consumer Disclosure Consent: Bundled Flow
Feedback
The DSB invites community feedback on these artefacts and any other CX guidelines seen as necessary to support the proposed August 2024 rules and associated data standards. This issue will be progressed in MI21.
The CX Guidelines provide optional implementation examples for key rules, standards, and best practice recommendations.
They demonstrate key aspects of the consent model, but certain areas may be considered out of scope. This may include, for example, where the rules and/or standards are silent or non-prescriptive to provide CDR participants with flexibility or discretion according to their own systems or protocols.
❗The CX Guidelines span policy, rules, standards, and best practice, so requests will be considered on a case by case basis and timings may not fall within a Maintenance Iteration cycle.
Importantly, the CX Guidelines are optional to follow, but the CDR rules require CDR participants to have regard to them. The CX Standards differ in that they are binding data standards that must be followed.
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